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COVID-19 Disaster Recovery dislocated worker grant

monitoring participant file checklist

LWDB:

MIS ID & Name:

Monitor(s):

Date:

Provider:

Co-enrolled

☐ Yes ☐ No

Program(s) / Enrollment Dates:

Date and Reason of Program Completion and/or System Exit:

ELEMENT

EVIDENCE & INDICATORS

determination & cOMMENTS

action required/ recommendations

COVID-19 Enrollment Exception

WIN 0109: Verbal Self-Attestation and Remote Eligibility Documentation

* Effective Date: March 23, 2020

*Expiration Date: May 18, 2021

Minimum Requirements for Documenting Eligibility for WIOA Title I-B Programs

Verbal self-attestation is allowed to document eligibility for criteria for which self-attestation is not otherwise allowed per DOL guidance but should not be used as a first resort. LWDBs and their service providers should attempt to collect eligibility source documentation when possible. However, while one-stop offices remain closed due to COVID-19 impacts, full verbal self-attestation is allowed if clearly documented in case files as follows:

(a.) The case manager and applicant conduct the eligibility determination and registration verbally by phone with the case manager case-noting the following in the ETO management information system:

i. That verbal self-attestation was necessary due to a one-stop office closure caused by COVID-19.

ii. Each eligibility and priority of service criterion to which the applicant is self-attesting with a statement that reads, “I attest that [applicant name] verbally self-attested to the eligibility and priority of service criteria cited above.”

iii. That the case manager has provided to the applicant the Equal Employment Opportunity and Complaint and Grievance Procedures and WIOA Title I-B Program Data Collection Certification information verbally or in hard copy and that the applicant verbally acknowledged understanding the information by a statement that reads, “I attest that I provided the Equal Employment Opportunity and Complaint and Grievance Procedures and WIOA Title I-B Program Data Collection Certification statements to [applicant name] on [date] and [applicant name] attested to understanding the information.”

(b.) If determined eligible per the process described in paragraph 1, the case manager verbally obtains from the applicant all information required for federal reporting and records the information in the appropriate sections and fields in the ETO management information system.

For up to date state and federal COVID guidance, please visit: https://wpc.wa.gov/policy/state/and/federal/COVID-19/guidance

COVID-19 Enrollment Exception continued…

WIN 0114, Change 1: COVID-19 Employment Recovery Dislocated Worker Grant (DWG) Guidance and Instructions

· Required documentation for COVID-19 Disaster Recovery DWG participants enrolled through the verbal self-attestation process must be collected within 30 calendar days of the date a one-stop center officially reopens, either in person or through the remote or virtual eligibility process, and eligibility must be validated based on the collected documentation.

· If any participants are determined ineligible after documentation is received, costs incurred before the discovery of ineligibility will not be questioned if they receive no further services. If documentation is not collected for such participants and they continue to receive services, they will be assumed ineligible and any costs incurred from that point forward for provision of services will be questioned.

☐ N/A, verbal self-attestation was not used to determine eligibility

· Verbal self-attestation was used to determine eligibility: (WIN 0109)

☐ YES, one or more of the following eligibility criteria were verbally self-attested (if documentation was provided for any of the eligibility criteria, refer to those respective parts in section 1 below):

☐ Legally Entitled to Work

☐ Selective Service Registration (if applicable)

☐ Category of Dislocation Criterion: (Case notes must include how they meet each criterion)

☐Category 1: General Dislocation

☐Termination, layoff, or notice of layoff

AND ☐Local area unlikely to return to previous occupation criteria (other than demand /decline)

AND ☐Eligible or exhausted UI compensation

OR ☐Not eligible for UI, but has a sufficient duration of attachment to workforce

☐ Category 2: Plant Closure / Substantial Layoff

☐Termination, layoff, or notice of layoff due to permanent closure or substantial layoff

OR ☐Employed at a facility which the employer made a general announcement that the facility will close within 180 days

☐ Category 3: Self-employed

☐Unemployed as a result of general economic conditions in the community in which they reside or because of natural disasters

☐ Category 4: Displaced Homemaker

☐Was dependent on the income of a family member and is no longer supported by that income

OR ☐Dependent spouse of an active duty military member whose family income is significantly reduced due to deployment, a call/order to active duty, or service-connected death or disability of the military member

AND ☐Unemployed or underemployed and experiencing difficulty obtaining or upgrading employment

☐ Category 5: Dislocated / Separated Military

☐Non-retiree military service member discharged or released from service under other than dishonorable discharge or who has received a notice of military separation

☐ Category 6: Military Spouse

☐Spouse of a member of the armed forces on active duty, and who has experienced a loss of employment as a direct result of relocation to accommodate a permanent change in duty station of such member

OR ☐Spouse of a member of the armed forces on active duty and who is unemployed or underemployed and is experiencing difficulty in obtaining or upgrading employment

☐Date of Dislocation for categories 1, 2, 3, 5 and 6

Continued on the next page…

· Verbal self-attestation was clearly documented by case-noting the following in ETO: (WIN 0109)

☐ YES, the following were located in case notes:

☐ That verbal self-attestation was necessary due to a one-stop office closure caused by COVID-19.

☐ Each eligibility and priority of service criterion to which the applicant is self-attesting.

☐ A statement that reads, “I attest that [applicant name] verbally self-attested to the eligibility and priority of service criteria cited above.”

☐ A statement that reads, “I attest that I provided the Equal Employment Opportunity and Complaint and Grievance Procedures and WIOA Title I-B Program Data Collection Certification statements to [applicant name] on [date] and [applicant name] attested to understanding the information.”

☐ NO, One or More Issue Identified

REPORTING:

· All demographics and required federal reporting information was collected and entered in ETO (WIN 0109)

☐ YES, No Issue Identified

☐ NO, One or More Issue Identified

Required Documentation Collection

· Eligibility documentation was collected for participant enrolled through verbal self-attestation, within 30 calendar days of the one-stop officially reopened. (WIN0114, change 1)

☐ N/A, one-stop not officially reopened

☐ N/A file was reviewed before deadline to collect documentation

☐ N/A, participant exited prior to one-stop officially reopening

☐ YES, No Issues Identified

☐ NO, One or More Issues Identified

☐ No Issues Identified

☐ Items to Address

☐ Questioned Cost

☐ Data Validation Issues

☐ Observation

☐ No Action Required

☐ Action Required

☐ Recommendation

1. WIOA DW ELIGIBILITY

Age/ Date of Birth

*Age is not a requirement for DW

TEGL 23-19:

· While age is not a requirement for DW Eligibility, DOL does require verification of age for Data Validation Purposes

Self-Attestation

ESD Policy 1019, Rev. 4:

· Self-attestation of age is acceptable for ISD co-enrollment, Basic Career Services only

· Full eligibility documentation is required for participants pursuing Individualized Career Services or Training Services

· Verification of age was in the file: (TEGL 23-19)

☐ YES, Validated by one of the following:

☐ Driver’s License or ID ☐ Federal, State, Local ID Card

☐ Birth certificate ☐ Passport

☐ Baptismal record ☐ DD-214

☐ Work permit ☐ Hospital record of birth

☐ Public assistance ☐ Social service records

☐ School records / ID’s ☐ Family bible

☐ NO, Unable to Validate

Reporting:

· Date of Birth is accurately recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Selective Service Registration

TEGL 11-11, Change 2

All males (U.S. citizens and aliens living in the U.S.) born after January 1, 1960 must be registered with Selective Service within 30 days of their 18th birthday.

Self-Attestation


· Self-attestation of Selective Service Registration is acceptable for ISD co-enrollment, Basic Career Services only

· Full eligibility documentation is required for participants pursuing Individualized Career Services or Training Services

Immigrants and Dual Nationals

https://www.sss.gov/register/immigrants/

Immigrant Men Are Required to Register

With very few exceptions, all immigrant males between ages 18 and 25 are required by law to register with the Selective Service System (SSS) within 30 days of arriving in the United States. This includes naturalized citizens, parolees, undocumented immigrants, legal permanent residents, asylum seekers, refugees, and all males with visas more than 30 days expired.

Non-Immigrant Foreigners

Non-immigrant men living in the United States on a valid visa are not required to register for as long as they remain on a valid visa up until they turn 26.

☐ N/A, participant was one of the following: (TEGL 11-11, change 2)

☐ Female

☐ Born before Jan. 1, 1960

☐ Non-US male, who entered the US for the first time after his 26th birthday, validated by one of the following:

☐ Date of entry stamp in passport

☐ I-94 with date of entry stamp

☐ USCIS letter with date of entry presented in conjunction with documentation of age

☐ Non-US male who entered the US illegally after his 26th birthday, validated by:

☐ Proof he was not living in the US from age 18-25

☐ Non-US male on a valid non-immigrant visa

· Participant was registered with Selective Service

or received a waiver: [WIOA Section 189(h)]

☐ YES, validated by one of the following: (ESD Policy 1019, Rev. 4)

☐ DD-214

☐ Online SS Verification

☐ SS Acknowledgement letter

☐ Selective Service Registration Card

☐ Selective Service Verification Form (Form 3A)

☐ Stamped Post Office Receipt of Registration

☐ Local area approved waiver documentation


Reporting:

· Selective Service Registration is recorded in MIS:

(20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Legally Entitled to Work in the U.S.

· Citizens;

· Nationals;

· Lawfully admitted permanent resident aliens;

· Refugees;

· Asylees;

· Parolees; and

· Other immigrants authorized by the Attorney General to work in the United States.

For a list of accepted I-9 Documentation, visit: https://www.uscis.gov/i-9-central/form-i-9-acceptable-documents

· Participant was eligible to work in the U.S.:

(WIOA Section 3(2); ESD Policy 1019, Rev. 4)

☐ YES, validated by one of the following: (ESD Policy 1019, Rev. 4)

☐ Accepted I-9 Documentation

☐ Self-attestation, which was one of the following:

· Signed and dated paper version from ESD Policy 1019, Rev. 4 or a substantially similar version:


☐ NO, one or more issues identified

· Signed and dated paper WIOA eligibility application:



· Signed and dated MIS WIOA Application:




Reporting:

· Eligibility to work in the U.S. is recorded in MIS:

(20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Temporarily or permanently laid off as a consequence of the disaster

WIN 0114, Attachment D

Question 3: What does temporary layoff mean exactly, regarding the Dislocated Worker Disaster Recovery Grant? We can’t find a definition outside of WARN. Does it refer to a standby or furloughed employee?

Answer: While WIOA does not provide a definition for “temporary layoff”, the term describes instances where an employer has no work currently available for employees but the employees have a reasonable expectation from the employer that they will return to work for that employer when more work is available. Such employees can be served under the COVID-19 Disaster Recovery Dislocated Worker Grant. To qualify for the Employment Recovery Grant, employees must be permanently laid off.

☐ N/A, not enrolled under this category

· Participant met the “Temporarily or Permanently laid off” eligibility criteria: (TEGL 12-19)

☐ YES, validated by one of the following: (ESD Policy 1019, Rev 4)











☐ Verification from employer

☐ Rapid Response list

☐ Notice of layoff

☐ Public announcement with crossmatch to UI wage records




☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

General Dislocation

Definition

ESD WS System Policy 1019, Rev. 4:

· An individual who was terminated, laid off, or received a notice of termination or layoff, AND

· Is determined unlikely to return to previous industry or occupation (as defined by LWDB policy), AND

· Is eligible for or has exhausted entitlement to unemployment compensation; OR

· Is not eligible for unemployment compensation but can show attachment to the workforce of sufficient duration.


· Participant met the “General Dislocation” eligibility criteria: (20 CFR 677.235)

















Reporting:

· General Dislocation is recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Plant Closure/ Substantial Layoff

Definition


· An individual who was terminated, laid off, or received a notice of layoff from employment at a plant, facility, or enterprise as a result of a permanent closure or substantial layoff; OR

· An individual employed at a facility at which the employer has made a general announcement that the facility will close within 180 days.


· Participant met the “Plant Closure/Substantial Layoff” eligibility criteria: (20 CFR 677.235)

















Reporting:

· Plant Closure or Substantial Layoff is recorded in MIS:

(20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Self-Employed

Definition


· Was self-employed (including employment as a farmer, rancher or fisherman), but is unemployed as a result of general economic conditions in the community in which the individual resides or because of natural disasters.

OR

Disaster Recovery DWG - Eligible Participants: 20 CFR 687.170(b):

· a self-employed individual who became unemployed or significantly underemployed as a result of the disaster or emergency.


· Participant met the “Self-employment” eligibility criteria: (20 CFR 677.235; TEGL 12-19)












☐ UI wage records

☐ Other:


Reporting:

· Self-Employed is recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Displaced Homemaker

Definition


· An individual who was dependent on the income of another family member and is no longer supported by the income of that family member; OR

· Is the dependent spouse of a member of the armed forces on active duty and whose family income is significantly reduced because of a deployment, a call or order to active duty, or a service-connected death or disability of the member. AND

· Is unemployed or underemployed and is experiencing difficulty in obtaining or upgrading employment.

*Date of Dislocation does not apply to Displaced Homemaker (TEGL 23-19)


· Participant met the “Displaced Homemaker” eligibility criteria: (20 CFR 677.235)












☐ Public assistance records

☐ Court papers

☐ Divorce papers

☐ Bank records

☐ Spouse’s layoff notice

☐ Spouse’s death record


Reporting:

· Displaced Homemaker is recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Dislocated/Separating Military Service Member

Definition


· A non-retiree military service member who was discharged or released from service under other than dishonorable or has received a notice of military separation (defined by LWDB).

· Retirement orders do not qualify as “terminated” or “laid off”.


· Participant met the “Dislocated or Separating Military Service Member” eligibility criteria: (20 CFR 677.235)
















☐ DD-214


Reporting:

· Dislocated or Separating Military Service Member is recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Military Spouse

Definition


· The spouse of a member of the armed forces on active duty, and who has experienced a loss of employment as a direct result of relocation to accommodate a permanent change in duty station of such member; OR

· The spouse of a member of the armed forces on active duty and who is unemployed or underemployed and is experiencing difficulty in obtaining or upgrading employment.


· Participant met the “Military Spouse” eligibility criteria: (20 CFR 677.235)

















Reporting:

· Dislocated or Separating Military Service Member is recorded in MIS: (20 CFR 677.235)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

A Long-term Unemployed Worker

TEGL 19-16; PIRL; TEGL 23-19:

· Long-term unemployed - unemployed for 27 or more consecutive weeks

TEGL 23-19, Attachment 2

Long-Term Unemployed at Program Entry

WIOA Source Documentation

One of the following:

• Self-Attestation

• Public Assistance Records

• Refugee Assistance Records

• Cross-Match with Public Assistance Database

• Cross-Match to State UI Database

☐ N/A, Not enrolled under this category

· Participant met long-term unemployed eligibility criteria: (TEGL 23-19)

☐ YES, validated by one of the following: (TEGL 23-19)

☐ Self-Attestation

☐ Public Assistance Records

☐ Refugee Assistance Records

☐ Cross-Match with Public Assistance Database

☐ Cross-Match to State UI Database

☐ No, Unable to validate



☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Date of Actual Dislocation

*Date of Dislocation does not apply to Displaced Homemaker (TEGL 23-19)

☐ N/A, enrolled as a Displaced Homemaker

· Date of Dislocation was documented in the file:

(20 CFR 677.235)
















☐ NO, Could Not Locate

Reporting:

· Date of Dislocation is recorded in MIS: (20 CFR 677.235)

☐ N/A, Displaced Homemaker





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Under-Employed Workers and

Stop-Gap Employment

Under-employed Workers


· Dislocated from full-time employment and meets one of the following eligibility criteria:

· Employed less than full-time but actively seeking full-time employment, or

· Employed in a position that is inadequate with respect to documented skills and training, or

· Employed but meet the definition of “low-income” in WIOA Section 3(36), or

· Employed but current earnings are insufficient compared to earnings from previous employment.

Stop-Gap Employment


· Temporary employment that will not lead to self-sufficiency,

· Accepted only because they have been laid off from the customary work for which their training, experience or work history qualifies them.

· Intend to end stop-gap employment upon completion of training, obtaining self-sufficient employment or as specified in the individual employment plan (IEP).

· Typically, pays less than the individual’s wage of self-sufficiency (as defined by the LWDB), but with exception per local policy.

☐ N/A, not employed at enrollment

UNDER-EMPLOYED WORKER

☐ N/A

· Participant met the “Under-Employed Worker” eligibility criteria: (ESD Policy 1019, Rev. 4)

☐ YES, No Issues Identified:

☐ Employed less than full-time but actively

seeking full- time employment,

☐ Employed in a position that is inadequate with

respect to documented skills and training, or

☐ Employed but meet the definition of low-

income” in WIOA Section 3(36)

☐ Employed but current earnings are insufficient

compared to earnings from previous

employment


STOP-GAP EMPLOYMENT

☐ N/A

· Participant met “Stop-Gap” employment criteria:

(ESD Policy 1019, Rev. 4):

☐ YES, no Issues identified

☐ Employment was temporary and not self-

sufficient (unless exempt per local policy)

☐ Unable to find employment customary to their

training, experience or work history

☐ Intend to end employment upon completion

of training or as specified on IEP




☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

2. program enrollment

Date of Program Entry, Participation

Participant

20 CFR 680.110:

(a) Individuals are considered participants when they have received a WIOA service other than self-service or information-only activities and have satisfied all applicable programmatic requirements for the provision of services, such as eligibility determination.

(b) Adults who receive services funded under Title I other than self-service or information-only activities must be registered and must be a participant.

WS System Policy 1020 Handbook:

· Date of participation is initiated by the first program-funded qualifying service.

FILE REVIEW:

· Participant met all programmatic eligibility requirements: [20 CFR 680.110 and TEGL 19-16)



· There is documented evidence indicating a service other than self-service or information only activities were provided to the participant initiating program participation: [20 CFR 680.110) and TEGL 19-16; TEGL 23-19]

☐ YES, documented on one of following: (TEGL 23-19)

☐ Individual Plan for Employment

☐ Electronic Records

☐ Program intake documents such as eligibility

determination documentation or program

enrollment forms


Reporting:

· A service other than self-service or information-only activities is recorded in MIS on date of program enrollment: (20 CFR 680.110) and TEGL 19-16; TEGL 23-19)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Concurrent Program Enrollment

Tracking of Funds

TEGL 19-16

· Local program operators must identify and track the funding streams which pay the costs of services provided to individuals who are concurrently enrolled, and

· Ensure no duplication of services.

☐ N/A, Not co-enrolled at time of monitoring

Reporting:

· Program enrollments are correctly recorded in MIS: (20 CFR 677.160)



· Services are correctly recorded in MIS and assigned to the appropriate program: (20 CFR 677.160)



· No duplication of services between co-enrolled programs were observed at the time of review:

(TEGL 19-16)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Veteran Status at Participation

☐ N/A

Documentation of participant’s veteran/eligible spouse status is located in the file: (TEGL 23-19)

☐ YES, documented on one of the following:

☐ DD-214

☐ Letter from the Veteran’s Admin.

☐ Other:


Reporting:

· Veteran status is recorded in MIS:





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

3. services

Support Services

MIS

WIN 0077, Change 9; WorkSource Services Catalog:

· Program Support Services-Other (3.0)

· This service is used when the support services being provided does not fall into the transportation category. This may include assistance with clothing, counseling, family/health care, housing, tools, union dues, driver’s licenses, or car repairs, assistance with books, fees, and school supplies, and payments for employment and training-related applications, tests, and certifications.

· The purpose of support services is to offer a resource for participants who are actively engaged in job search, work activities or training. Support services should be provided based on the real and immediate needs of the participant.

· Program Support Services-Transportation

Support services to be provided to participants prior to job placement and exiting the program. Transportation support are goods in the form of transportation assistance. The purpose of support services is to offer a resource for participants who are actively engaged in job search, work activities or training. Support services should be provided based on the real and immediate needs of the participant.

Eligibility to Receive Supportive Services

TEGL 12-19:

Supportive services are allowable when they are needed to enable individuals to participate in disaster relief employment and employment and training services and when supportive services cannot be obtained through other programs. Supportive service policies for a disaster project must align with the state or local area supportive service policy; any supportive services provided must be consistent with WIOA.

20 CFR 680.910:

(a) Supportive services may only be provided to individuals who are:

(1) Participating in career or training services as defined in WIOA secs 134(c)(2) and (3); and

(2) Unable to obtain supportive services through other programs providing such services.

(b) Supportive services may only be provided when they are necessary to enable individuals to participate in career services or training services.

Reporting / MIS Requirements


· Supportive services can be provided to Adults and DW (except during follow-up or after exit) subject to also receiving a career and training services (supportive services cannot be the only service in a participant record).

· The supportive service can be record on or after the date of the career or training service and should also include a case note explaining how the supportive service connects to a career or training service.

☐ N/A, no documented evidence service(s) provided

· Supportive services were necessary to enable the individual to participate in career and training services: (20 CFR 680.910; TEGL 19-16)



· Supportive services were provided with WIOA funds only when the participant was unable to obtain supportive services through other resources and/or programs providing such services: [20 CFR 680.910(a)(2)]



· Documentation of supportive services is on file and meets local policy requirements: (ESD WIOA Policy 5602, rev. 2)



Reporting:

· For Supportive Services, a qualifying career or training service was provided to the participant and is recorded in MIS in conjunction to the supportive services recorded in MIS:

(WIN 0078, Rev. 1; ESD Policy 1019, Rev. 4)


☐ NO, on one or more occasion, no supportive service is recorded in MIS

☐ NO, on one or more occasion, no qualifying service is recorded in MIS



☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

training services

Occupational Skills Training

MIS


· Training, Occupational Skills Training (2.0):

· An organized program of study for adults and dislocated workers that provides specific vocational skills that lead to proficiency in performing actual tasks and technical functions required by certain occupational fields at entry, intermediate, or advanced levels.

Eligibility

20 CFR 680.210: Training services may be made available to employed and unemployed adults who:

(a) A one-stop center or one-stop partner determines, after an interview, evaluation or assessment, and career planning, are:

1) Unlikely or unable to obtain or retain employment that leads to economic self-sufficiency or wages comparable to or higher than wages from previous employment through career services;

2) In need of training services to obtain or retain employment leading to economic self-sufficiency or wages comparable to or higher than wages from previous employment through career services;

3) Have the skills and qualifications to participate successfully in training services;

(b) Select a program of training services that is directly linked to the employment opportunities in the local area or the planning region, or in another area to which the individuals are willing to commute or relocate;

(c) Are unable to obtain grant assistance from other sources to pay the costs of such training, including such sources as State-funded training funds, TAA, and Federal Pell Grants, or require WIOA assistance in addition to other sources of grant assistance, including Pell Grants.

Documentation Requirements

20 CFR 680.220:

(b) The case file must contain a determination of need for training services as determined through the interview, evaluation, or assessment, and career planning informed by local labor market information and training provider performance information, or through any other career service received. There is no requirement that career services be provided as a condition to receive training services; however, if career services are not provided before training, the Local WDB must document the circumstances that justified its determination to provide training without first providing the services described in paragraph (a) of this section.

3-D. Occupational Skills Training, continued…

Individual Training Accounts (ITA)

TEGL 19-16:

Training services, when determined appropriate, must be provided either through an Individual Training Account (ITA) or through a training contract discussed in Section 8 of this TEGL. Except in certain instances listed in WIOA sec. 122(h) and 20 CFR sec. 680.320, training services must be provided by an Eligible Training Provider (ETP) in accordance with WIOA sec. 122(d).

Use of ITA Funds

ESD Policy 5601, Rev 2:

If an ITA has been established and the training is managed between the WIOA Title I case manager and the participant, those funds may be used to pay for allowable training-related expenses as well as tuition expenses.

If the training provider was selected by the WIOA Title I participant and the case manager, but the source of payment for training is Pell, other financial aid, or private scholarships, a WIOA-funded ITA may be used to pay allowable training costs not covered by those fund sources.

A WIOA-funded ITA is not appropriate if the WIOA Title I case manager and program played no role in training provider selection and the participant’s training is selected, funded, and directed by a program other than Title I, such as Vocational Rehabilitation (VR), Trade Adjustment Assistance (TAA), or community and technical colleges (Worker Retraining (WRT). However, if such funding ends after training has started, a WIOA Title I-funded ITA may be initiated if that program is on the Eligible Training Provider (ETP) list.

In-demand Occupations


ITA funds must be directly linked to an in-demand industry sector or occupation in the local area, or in another area to which the individual is willing to relocate. Local boards may also approve training services for occupations determined by the local board to be in economic sectors that have high potential for sustained demand or growth in the local area.

DOL guidance is that registered apprenticeship programs are in-demand even if the labor market information may not list as “in-demand” the occupation for which the individual is apprenticed because registered apprenticeship programs, being tied to specific employers, only enroll individuals when there is employer demand, which makes it possible to carry out the on-the-job aspect of the instruction.

☐ N/A, no evidence this service was provided

FILE REVIEW:

· Participant attended a post-secondary education program that leads to a credential or degree from an accredited post-secondary education institution at any point during program participation: (TEGL 23-19)

☐ N/A

☐ YES, Validated by one of the following: (TEGL 23-19)

☐ Copy of enrollment record

☐ File documentation with notes from program staff

☐ Vendor training documentation


☐ Individual Training Account

☐ Attendance Records

☐ No, Unable to Validate

· Established Individual Training Account (ITA) (TEGL 23-19)

☐ N/A, training provided through contract or under an exception listed in 20 CFR 680.320


☐ Case notes

☐ ITA approval, Allocation or Activation Records


· Participant was unlikely or unable to obtain or retain employment that leads to economic self-sufficiency or wages comparable to or higher than wages from previous employment through career services: [20 CFR 680.210(a)(1)]



· The participant needed training to obtain or retain

employment leading to economic self-sufficiency or wages comparable to or higher than wages from previous employment: [20 CFR 680.210(a)(2)]



· The participant had the skills and qualifications to participate successfully in training: [20 CFR 680.210(a)(3)]



· Training is linked to in-demand employment opportunities in local area or area in which they are willing to commute or relocate: [20 CFR 680.210(b)]



· Evidence of participant’s satisfactory progress in training is in the file: (WIOA Final Rule, narrative page 56177; ESD Policy 5601, Rev. 2)

☐ N/A-training not started/progress not yet provided



· Date participant enrolled in training is documented in the file:

(TEGL 23-19)




☐ School Records

☐ Transcript or report cards


· If the participant withdrew from training, the reason for withdrawing and the revision to the participant’s employment and training plan is documented: (WIN 0088)

☐ N/A, participant did not withdraw from training

☐ YES, reason for withdrawal is documented and revision to participant’s employment and training program is documented.

☐ NO, could not locate documentation for reason for

withdrawing from training and/or revision to plan

· Evidence of training outcome is in the file: (20 CFR 677.235)

☐ N/A-still active in service

☐ YES, Documented on one of the following: (TEGL 23-19)

☐ Copy of credential

☐ Copy of school record

☐ Follow-up survey from program participants

☐ Case notes documenting information obtained from education or training provider


Reporting:

· Date withdrew/completed training is recorded in MIS:

(TEGL 23-19; WIN 0088)

☐ N/A-still active in service


☐ Crossmatch between state MIS and attendance sheets or records

☐ Vendor training records with follow-up crossmatch to state MIS database

☐ Case notes with follow-up crossmatch to state MIS database

☐ NO, Unable to Validate if the participant is still in training

☐ NO, date withdrew/completed training is not recorded in MIS

· Date participant actually began training is accurately recorded in MIS (ETA PIRL 9170, TEGL 23-19)


☐ Crossmatch between state MIS and attendance sheets or records

☐ Vendor training records with follow-up crossmatch to state MIS database

☐ Case notes with follow-up crossmatch to state MIS database

☐ ITA

☐ NO, date participant began training is not recorded in MIS



☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Consumer Choice (Occupational Skills Training Continued)

20 cfr 680.340:

(a) Training services, whether under ITAs or under contract, must be provided in a manner that maximizes informed consumer choice in selecting an eligible provider.

(b) Each Local WDB, through the one-stop center, must make available to customers the State list of eligible training providers required in WIOA sec. 122(d).

☐ N/A, not participating in applicable training service

· Eligible Training Provider List (ETPL) was made available to the participant: [20 CFR 680.340(b)]



· Training was outside of WA State and met the requirements of local policy and ESD WIOA Policy 5611, Rev. 1:

☐ N/A





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Financial Aid; Other Program / Grant Assistance (Occupational Skills Training Continued)

Coordination of WIOA Training Funds and other Federal Assistance


· Local areas must consider the availability of other sources of grants, excluding loans, to pay for training costs so that WIOA funds are used to supplement but not supplant other sources.

· WIOA funds are intended to provide training services in instances when there is no grant assistance (or insufficient assistance) from other sources (i.e., TANF, BFET, Title IV Programs and State-funded grants) to pay for those costs.

· The use of WIOA funds to pay down a loan of an otherwise eligible participant is prohibited; however, the mere existence of a federal loan must not impact eligibility determinations.

20 CFR 680.310

(d) An individual may select training that costs more than the maximum amount available for ITAs under a State or local policy when other sources of funds are available to supplement the ITA. These other sources may include Pell Grants; scholarships; severance pay; and other sources.

☐ N/A, not participating in applicable training service

· Availability of non-WIOA funds, excluding loans, was explored and outcome of efforts was documented:

(20 CFR 680.230)

· FAFSA/other resources such as TAA, TANF, BFET, Worker Retraining, Title IV programs, and State-funded grants, etc. were explored first, and not available, utilizing WIOA funds as a last dollar resource:


☐ NO, Could Not Validate

· Outcome of FAFSA/other resources explored was documented:



· If applicable, Dept. of Veterans Affairs training funds were exempt from the “other sources of training grants” requirement: (WIOA Final Rules)

☐ N/A





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Adult Education & Literacy Activities

MIS


· Training, Adult Education and Literacy with Training (2.0):

· Adult education and literacy instruction is intended to upgrade basic skills in order to prepare the individual for further training, future employment, or retention in present employment. Includes remedial reading, writing, mathematics, literacy training, study skills, English for non-English speakers, bilingual training, and GED preparation (including computer assisted competency training, and school to post-secondary education transition).

· This group must be offered in combination with other allowable training services (not including transitional jobs or customized training).

· If not in combination with training, this group must be recorded as a career service.

ETA 9170 (PIRL): If the participant received services under WIOA Title II defined as academic instruction and education services below the post-secondary level that increases an individual’s ability to-

· Read, write, and speak in English and perform mathematics or other activities necessary for the attainment of a secondary school diploma or its recognized equivalent;

· Transition to post-secondary education and training; and

· Obtain employment

Training Requirement

20 cfr 680.350:

· WIOA funds may provide adult education and literacy activities if they are provided concurrently or in combination with one or more of the following training services:

(a) Occupational skills training, including training for nontraditional employment;

(b) OJT;

(c) Incumbent worker training;

(d) Programs that combine workplace training and related instruction, which may include cooperative education programs;

(e) Training programs operated by the private sector;

(f) Skill upgrading and retraining; or

(g) Entrepreneurial training.

☐ N/A, no documented evidence service was provided

· If WIOA funds were used for the Adult Education & Literacy Activities, they were provided in concurrence with any of the training activities in WIOA sec. 134(c)(3)(D)(i)–(vii) and 20 CFR 680.350.

☐ YES, provided concurrently with one or more of the following training services:

☐ Occupational Skills Training, including training for nontraditional employment

☐ On-the-job Training (OJT)

☐ Incumbent Worker Training (IWT)

☐ Programs that combine workplace training and related instruction, which may include cooperative education programs

☐ Training programs operated by the private sector

☐ Skill upgrading and retraining

☐ Entrepreneurial training


Secondary Education Program at or above the 9thGrade Level:

· Participant attended a program designed to lead to a HS equivalent credential (GED) at program enrollment or at any point while participating in the program: (TEGL 23-19)

☐ N/A




☐ School Records

☐ Transcript or report card

☐ Data match to State K-12 data system




☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

work-based training

On-the-Job Training (OJT)

MIS


· Training, On-the-Job Training (2.0):

· Training provided by an employer to a paid participant while engaged in productive work in a job that improves knowledge or skills essential to the full and adequate performance of the job;

· Provides reimbursement to the employer of up to 75% of the wage rate of the participant, for the extraordinary costs of providing the training and additional supervision related to the training;

· Limited in duration as is appropriate to the occupation for which the participant is being trained, taking into account the content of the training, the prior work experience of the participant, and the service strategy of the participants, as appropriate.

ojt Definition & Design

WIOA Sec. 3(44): The term “on-the-job training” means training by an employer that is provided to a paid participant while engaged in productive work in a job that-

(A) Provides knowledge or skills essential to the full and adequate performance of the job;

(B) Is made available through a program that provides reimbursement to the employer of up to 50% of the wage rate of the participant, except as provided in section 134(c)(3)(H), for the extraordinary costs of providing the training and additional supervision related to the training; and

(C) Is limited in duration as appropriate to the occupation for which the participant is being trained, taking into account the content of the training, the prior work experience of the participant, and the service strategy of the participant.

OJT Wages & Benefits

20 CFR 683.275:

(a) Individual in OJT must be compensated at the same rates, including periodic increase, as trainees or employees who are similarly situated in similar occupations by the same employer and who have similar training, experience, and skills.

(c) Individuals in OJT must be provided benefits and working conditions at the same level and to the same extent as other trainees or employees working a similar length of time and doing the same type of work.

Continued on the next page…

On-the-Job Training (OJT), continued…

ojt Contracts

20 CFR 680.710: OJT contracts may be written for eligible employed workers when:

(a) The employee is not earning a self-sufficient wage or wages comparable to or higher than wages from previous employment;

(b) The requirements of sec. 680.700 are met; and

(c) The OJT relates to the introduction of new technologies, introduction to new production or service procedures, upgrading to new jobs that require additional skills, workplace literacy, or other appropriate purposes identified by the Local WDB.

WIOA Final Rules, page 56149:

· OJT contracts must be continually monitored so that WIOA funds provided through OJT contracts are providing participants the training to retain employment successfully.


· The participant’s work experience and existing knowledge and skills were considered when developing the OJT: [WIOA Sec. 3(44)]



· Contracts, time sheets, performance evaluations, and similar documentation supporting the OJT was on file for the participant: (DOL, State guidance)



☐ Contract(s)

☐ Time sheets

☐ Performance evaluations

· Knowledge and skills essential to the full and adequate performance of the job was documented: [WIOA Sec. 3(44)]



· The length of the OJT was appropriate to the occupation for which the participant was trained. [WIOA Sec. 3(44)]



· The participant was compensated at the same rate and provided benefits and working conditions as other employees in similar occupations by the same employer: (20 CFR 683.275)



· The OJT did not displace or partially displace other employees of the employer: [WIOA Sec. 181(b)]



· Written concurrence of the labor organization and employer was obtained, if applicable: [WIOA Sec. 181(b)]

☐ N/A



· The OJT was developed with an employer who does not continuously fail to provide long-term employment with equal benefits and wages: [WIOA Sec. 194(4)]



· The service provider confirmed the employer had not relocated less than 120 days prior to the OJT and did not lay off employees at the prior location: [WIOA Sec. 181(d)]



· Factors were documented if employer was reimbursed above 50% and up to 75%: [20 CFR 680.730(b); TEGL 19-16]

☐ N/A



· OJT contract was regularly monitored: (WIOA Final Rules, page 56149)





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Internship or Work Experience (WEX)

MIS


· Individualized, Work/Internship Experience:

· For adults and dislocated workers, work experience is a planned, structured learning experience that takes place in a workplace for a limited period of time and is linked to a career. Work experience may be paid or unpaid, as appropriate. A work experience workplace may be in the private for-profit sector, the non-profit sector, or the public sector. Labor standards apply in any work experience where an employee/employer relationship, as defined by the Fair Labor Standards Act, exists.

Definition

20 CFR 680.180:

· An internship or work experience is a planned, structured learning experience that takes place in a workplace for a limited period of time.

· Internships and other work experience may be paid or unpaid, as appropriate and consistent with other laws, such as the Fair Labor Standards Act.

· An internship or other work experience may be arranged within the private for-profit sector, the non-profit sector, or the public sector.

· Labor standards apply in any work experience setting where an employee/employer relationship, as defined by the Fair Labor Standards Act, exists.


FILE REVIEW:

· Contracts, time sheets, performance evaluations, and similar documentation supporting the WEX was on file for the participant: (DOL, State guidance)


☐ NO, Unable to Locate

☐ Contract(s)

☐ Time sheets

☐ Performance evaluations



☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Disaster-Relief Employment

WIN 0114, Change 1

Disaster Relief Employment

Two types of disaster relief employment are allowed:

1. Clean-up and recovery efforts including demolition, repair, renovation and reconstruction of damaged and destroyed structures, facilities and lands located within the disaster area and in offshore areas related to the emergency or disaster. These can be implemented upon execution of local contracts.

2. Employment related to the delivery of appropriate humanitarian assistance in the immediate aftermath of the disaster or emergency. These can only be implemented upon execution of local contracts and based on alignment with activities approved by DOL as reflected in Attachment C.

Additionally, Attachment B outlines the criteria for selection of temporary work sites for Subsidized Disaster Relief Employment, as allowed in TEGL 12-19, Attachment I.

Attachment C – Humanitarian Assistance Disaster Relief Employment Approved by DOL

http://media.wpc.wa.gov/media/WPC/adm/policy/Disaster%20Relief%20Employment%20COVID-19.pdf

NOTE: Requests for approval must be submitted to the grant manager before any disaster-relief employment work on private property. Requests for work on private property must describe how they meet the criteria described on page 6 of TEGL 12-19.

Question 8: Is there a specific vehicle or approach that DOL requires in order to reimburse the employer for the temporary employment wages, benefits, and insurance for the Disaster Recovery Dislocated Worker Grant? Are there state policies that can provide guidance on this?

Answer: Per DOL Region 6, there is no specific or dictated vehicle or approach for reimbursing the employer for costs (wages, benefits, insurance, etc.) associated with DRDWG-related temporary employment. If there was, it would be stipulated in TEGL 12-19. That said, DOL recommends following state and local policy for doing contracts while keeping in mind that this would be a service delivery contract that does not require competitive procurement.

WIOA Title I Policies 5200 Revision 2, Fiscal Definitions, and 5250, Subrecipient Contracting and Pass-Through Entity Determination Requirements, apply broadly in that they refer to contractors, though neither specifically address this situation. We recommend you apply your local contracting policy as appropriate.


· Contracts, time sheets, performance evaluations, and similar documentation supporting the Disaster-Relief Employment was on file for the participant: (DOL, State guidance)



☐ Contract(s)

☐ Time sheets

· Worksite Documentation included all of the following:

☐ Explanation of how the temporary Disaster Relief Employment position supports:

☐ A COVID-related activity endorsed by the city, county, or other emergency management entity or entities, or;

☐ A COVID-related activity conducted by a local government, non-profit, or other community-based organization that has been assessed as such after review by the LWDB.

☐ All of the following details for each selected location could be validated:

☐ Name and location of the worksite;

☐ Whether it is public or private property;

☐ Number of participants working on the site;

☐ Dates of work on a site;

☐ Description of work performed at the site; and

☐ Written determination of how this site was approved, per the guidance outlined in this document and the documents referenced herein.


☐ NO, Unable to Validate One or More Item

· Justification of comparable wages or documentation of review of comparable wages was located for the participant / position:



· Disaster Relief Employment was one of the approved positions on Attachment C of WIN 0114, change 1:



· Worksite agreement language addresses the 12 months or 2,080 hours limitation:





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

Transitional Jobs

mis


· Individualized, transitional Job:

· A transitional job is a training service that is a subsidized, time-limited work experience with a public, private, or nonprofit employer for individuals with barriers to employment who are chronically unemployed or have an inconsistent work history to establish a work history that will lead to retention in unsubsidized employment. This service must be provided in combination with career services and/or support services. If it is not, it must be recorded as a work experience and/or internship.

Program Design and Eligible Participants

20 CFR 680.190:

· A transitional job is one that provides a time-limited work experience that is wage-paid and subsidized, and is in the public, private, or not-for-profit sectors for those *individuals with barriers to employment who are chronically unemployed or have inconsistent work history, as determined by the Local WDB.

· Transitional jobs must be combined with comprehensive career services and supportive services.

TEGL 19-16:

· This service must be combined with career and supportive services.

Individuals with a Barrier to Employment

WIOA sec. 3(24):

(1) Displaced homemakers;

(2) Low-income individuals;

(3) Indians, Alaska Natives, and Native Hawaiians;

(4) Individuals with disabilities;

(5) Older individuals, i.e., those aged 55 or over

(6) Ex-offenders;

(7) Homeless individuals;

(8) Youth who are in or have aged out of the foster care system;

(9) Individuals who are English language learners, individuals who have low levels of literacy, and individuals facing substantial cultural barriers;

(10) Eligible migrant and seasonal farmworkers, defined in WIOA sec. 167(i);

(11) Individuals within 2 years of exhausting lifetime eligibility under TANF;

(12) Single parents (including single pregnant women);

(13) Long-term unemployed individuals;

(14) Other groups determined by the Governor to have barriers to employment.


· Participant met the definition of “individual with barrier to employment” as described in WIOA Sec. 3(24) and was chronically unemployed or had inconsistent work history as determined by the LWDB: (20 CFR 680.190)



· The Transitional Job was combined with comprehensive career services and supportive services:

(20 CFR 680.190 and TEGL 19-16)



· The service provider confirmed the employer had not relocated less than 120 days prior to the training and did not lay off employees at the prior location:

[WIOA Sec. 181(d)]





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

4. OUTCOMES

Date of Most Recent Measurable Skill Gains

-In-Program Performance Measure

Reporting/MIS Data Entry Requirements

Recording MSG in ETO instructions included Training 12 Meeting Minutes sent via email from Lynn Aue (ESD) on 8-7-19 and revised on 10-9-19:

· Test and Results Page

· Progress Report Page

· Element titled “Associated Program Enrollment” with a dropdown of cross-referenced active program enrollment values

· Required field: Element titled “Progress Report Type” with a dropdown of the following values: “Apprenticeship”, “OJT” and “Skills Progression”.

· Required field: Element titled “Is the progress satisfactory?” with response values of “Yes” and “No”.

· Element titled “Documentation” with the option to upload documents.

· Element titled “Notes” with a free form text field that allows 1200 characters.

· Report Card or Transcript page:

· Element titled “Associated Program Enrollment” with a dropdown of cross-referenced active program enrollment values.

· Required field: Element titled “Credits or Units” with a free form text field that only allows numeric characters.

· Required field: Element titled “Does this meet the state unit’s academic standards?” with response values of “Yes” and “No”.

· Element titled “Documentation” with the option to upload documents.

· Element titled “Notes” with a free form text field that allows 1200 characters

· Skill gains should be counted using the date on which they occur, not the date on which they are recorded, or documentation is received.

WIN 0098:

· The State has established the academic standards as a grade of “C” or better.

· 14-day requirement for real-time data entry does not apply

Continued on next page…

Date of Most Recent Measurable Skill Gains Continued…

☐ N/A, not participating in applicable services or no measurable skill gain documented at the time of monitoring

Educational Functioning Level (EFL):

☐ N/A

☐ YES, the most recent date the achieved at least one EFL is recorded in MIS and validated by one of the following:

(TEGL 23-19; DOL ETA PIRL 9170)

☐ Pre- and post-test results measuring EFL gain

☐ Adult High School transcript showing EFL gain through the awarding of credits or Carnegie units

☐ Post-secondary education or training enrollment determined through survey documentation or program notes.


Secondary Progress:

☐ N/A

☐ YES, the most recent date of the participant’s transcript or report card for secondary education for one semester showing that the participant is meeting the State unit’s academic standards (grade “C” or better per WIN 0098) is recorded in MIS and validated by one of the following: (TEGL 23-19; DOL ETA PIRL 9170)

☐ Transcript

☐ Report Card


Post-Secondary Progress:

☐ N/A

☐ YES, the most recent date of the participant’s transcript or report card for post-secondary education that shows a participant is meeting the State unit’s academic standards (grade “C” or better per WIN 0098) is recorded in MIS and validated by one of the following: (TEGL 23-19, DOL ETA PIRL 9170)

☐ Transcript

☐ Report card


Employer Training Milestones (e.g., OJT):

☐ N/A

☐ YES, the most recent date that the participant had a satisfactory or better progress report towards established milestones from an employer who is providing training is recorded in MIS and validated

by: (TEGL 23-19)

☐ Documentation of a skill gained through OJT or Registered Apprenticeship

☐ Contract and/or evaluation from employer or training provider

☐ Progress report from employer documenting skill gain


Industry Exams or Skills Progression:

☐ N/A

☐ YES, the most recent date the participant successfully passed an exam that is required for a particular occupation, or progress in attaining technical or occupational skills as evidenced by trade-related benchmarks such as a knowledge-based exam is recorded in MIS and validated by one of the following: (TEGL 23-19; DOL ETA PIRL 9170)

☐ Results of knowledge-based exam or certification of completion

☐ Documentation demonstrating progress in attaining technical or occupational skills through an exam or benchmark attainment

☐ Documentation from training provider or employer

☐ Copy of credential that is required for a particular occupation and only is earned after the passage of an exam


REPORTING:

· Measurable Skill Gains recorded in ETO:



· Case notes document the date achieved and type of the Measurable Skill Gain: (20 CFR 677.155(c)(5); WIN 0088)

☐ YES, very detailed

☐ YES, some detail

☐ Could not locate case notes for:

☐ Date Measurable Skill Gain achieved

☐ Type of Measurable Skill Gain




☐ Observation


☐ Action Required

☐ Recommendation

Date attained & Type of Recognized Credential

In-Program and Exit-Based Performance Indicator

Types of Acceptable Credentials

TEGL 10-16, Change 1: The following are acceptable types of credentials that count toward the credential attainment indicator:

· Secondary school diploma or recognized equivalent

· Associate degree

· Bachelor’s degree

· Graduate degree for purposes of the VR program

· Occupational licensure

· Occupational certificate, including Registered Apprenticeship and Career and Technical Education educational certificates

· Occupational certification

· Other recognized certificates of industry/occupational skills completion sufficient to qualify for entry-level or advancement in employment.

Certificates / Credentials not Included

ESD Policy 1020 Data Integrity and Performance Policy and Handbook: Credentials that do not count include, but are not limited to:

· First aid cards

· Food handler’s card

· Non-commercial driver’s license

· Completion of WEXs

Evan Rosenberg, Division of Youth Services, DOL ETA, “WIOA Youth Eligibility Live Q&A Session” on WorkforceGPS October 24, 2017: Even though DOL will not define what counts as a credential, Evan did state the following common trainings do not count as a credential or occupational skills training:

· CPR

· OSHA 10

· Work readiness

· Completion of assistive technology training program (screen reading software)

· Certificates related to hygiene and safety that are broadly required for entry level employment

☐ N/A not participating in applicable services, or no

credential documented at time of monitoring

· Documentation of date and type of Credential Earned is located in the file: (TEGL 23-19)

☐ YES, Documented on one of the following: (TEGL 23-19)

☐ Copy of credential

☐ Copy of school record

☐ Follow-up survey from program participants

☐ Case notes documenting information obtained

from education or training provider

☐ NO, Unable to Locate:

☐ Date credential earned

☐ Type of credential

Reporting:

· Type of Credential Earned is recorded in MIS:

(20 CFR 677.160)


☐ Yes, but on one or more occasion, the incorrect

credential is recorded

☐ NO, on one or more occasion, no credential

recorded

☐ Unable to Validate credential earned recorded in

MIS

· Type of credential earned is documented in case notes: (WIN 0088)


☐ NO, on one or more occasions, type of credential

earned is not documented in case notes

☐ NO, on one or more occasion, type of credential

documented in case notes does not match credential recorded in MIS

☐ NO, one or more credential was not recorded in MIS




☐ Observation


☐ Action Required

☐ Recommendation

5. PROGRAM Exit

Date and Reason for Program Exit

Exit

ESD Policy 1020 Handbook:

· “Exit” refers to a participant who has not received a qualifying service funded by any qualifying program in the WorkSource system for 90 consecutive calendar days and is not scheduled to receive future qualifying services.

20 CFR 677.150(c)(1):

· Exit is the last day of service.

ETA 9170 (PIRL):

· The last date the participant received services that are not self-service, information-only, or follow-up services.

· And only if there are no future services that are not self-service, information-only or follow-up services, planned from the program.

Reporting /MIS Requirements

TEGL 23-19 – Date of Program Exit (WIOA)

· Record the last date the participant received services that are not self-service, information only, or follow-up services.

· Record the last date of receipt of services only if there are no future services that are not self-service, information-only, or follow-up services planned from the program.

· For Titles I, II and III, record the last date of funded service(s).

Other Reasons for Exit

TEGL 23-19:

· Incarcerated in a correctional institution or has become a resident of an institution or facility providing 24-hour support such as a hospital or treatment center during the course of receiving services as a participant.

· Medical treatment expected to last longer than 90 days and precludes entry into unsubsidized employment or continued participation in the program.

· Deceased

· Member of National Guard or other reserve military unit of the armed forces and is called to active duty for at least 90 days.

Program Completion


· The date of program completion is the date of the final program-funded qualifying service.

· In this sense, it is unlike the exit date, which is common across all programs rather than specific to a particular program.

· The program completion date may or may not be the same as the exit date. The program completion date will be equal to or less than the exit date.

Program Completion vs. System Exit


· Exit dates are not the same as program completion dates.

· A system exit date is the same as a program completion date only when participants do not receive a qualifying service from another program within 90 days.

☐ N/A, there is evidence the participant has not

completed the program

file review:

· Date of program exit is documented in the file:


☐ Copy of the letter sent to the individual indicating that the case was closed.

☐ WIOA Status/Exit Forms

☐ Electronic records

☐ Attendance Records

☐ Review of service records identifying the last

qualifying service (and lack of a planned gap)


· If program exit was due to “Other Reasons for Exit”, evidence is documented in the file:

☐ N/A


☐ File documentation with notes from program

staff

☐ Information from partner services

☐ WIOA status/exit forms


☐ Withdrawal form with explanation

☐ Information from institution or facility


Reporting:

· All durational services recorded in MIS are closed:

(20 CFR 677.160)

☐ N/A



· Program Completion Date recorded in MIS matches the date of the last qualifying recorded in MIS:



· Case notes document the date and reason for program completion: (WIN 0088)

☐ YES, very detailed

☐ YES, some detail

☐ NO, could not locate case notes for:

☐ Date of program completion

☐ Reason for program completion




☐ Observation


☐ Action Required

☐ Recommendation

Follow-up Services

MIS

WIN 0077, Change 9; WorkSource Service Catalog

When to Provide Follow-up Services

ESD WIOA Policy 5620:

· As instructed in TEGL 10-16, follow-up services can only be provided to WIOA Adult and DW participants who are placed in unsubsidized employment and have system exited.

· Follow-up services, if requested by the exited individual and determined by staff to be appropriate, must be provided for a period of up to 12 months.

☐ N/A, participant not placed in UE and/or has not yet

exited, or opted out of follow-up services

Reporting:

· Follow up services included more than a contact attempted: [20 CFR 681.580(c)]





☐ Questioned Cost


☐ Observation


☐ Action Required

☐ Recommendation

6. Data Validation, Data Integrity

MIS

Reporting / MIS Requirements

WIN 0082, Change 1: The minimal ETO data entry requirements are as follows:

· Services must be entered at the point in time they are delivered;

· If services cannot be entered at the time they are delivered, Basic Services and ITSS services must be entered within 14 calendar days of service delivery and the service date entered must always reflect the date the service was delivered.

· For any Activity Start Date of Basic and ITSS services errors identified after the 14-day calendar restriction, staff must correct the errors and request Department Head review and approve the correction. Department Head approval must be documented with a case note. The case note must identify the service name, the reason for the correction, and the Department Head’s review and approval of the correction.

· When a service is provided, the appropriate qualifying service must be identified, even if case notes are entered.

· Qualifying services are identified in the WorkSource Service Catalog.

· Services should only be entered when delivered to a participant and only actual services should be entered

· Case notes should support, not contradict service entries.

· Case notes should not be entered to represent service delivery without also entering a qualifying service from the WorkSource Service Catalog.

· Services should not be recorded if only a voice message was left, or an email delivered as they only represent the intent to provide service as opposed to the actual provision of services.

ESD Policy 1023:

· All services must be linked to an Active Program Enrollment.

summary of MIS observations:

· Participant’s demographic information is accurately recorded in MIS: (20 CFR 677.235)



· Employment Status at Program Entry is recorded in MIS: (20 CFR 677.235)



· All basic and/or individualized services provided to the participant (as identified in case notes or other documentation in the file) are recorded in MIS: (20 CFR 677.240; WIN 0082)



· For services recorded in MIS, services are attached to the appropriate programs: (ESD Policy 1023)



· For services recorded in MIS, services are recorded correctly: (20 CFR 677.240; WIN 0082)



· For services recorded in MIS, services are recorded within the allotted timeframes: (WIN 0082)



· For services recorded in MIS, appropriate outcomes are recorded: (20 CFR 677.240; WIN 0082)

☐ N/A






☐ Observation


☐ Action Required

☐ Recommendation

Case Notes

DOL Definition

TEGL 23-19: Paper or electronic statements by the case manager that identifies, at a minimum, the following:

· A participant’s status for a specific data element,

· The date on which the information was obtained and

· The case manager who obtained the information.

Reporting

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Documents

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